Open Air Fit Privacy Notice
1. Scope
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
2. Responsibilities
2.1 The Compliance Manager is responsible for ensuring that this notice is made available to data subjects prior to Open Air Fit Limited collecting/processing their personal data.
2.2 All Staff of Open Air Fit Limited who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
3. Privacy notice
3.1 Who are we?
Open Air Fit offers a range of fitness classes and programs for children and adults of all ages, ability and fitness levels on Wandsworth and Clapham Common.
Our Compliance Manager and data protection representatives can be contacted directly here:
- info@openairfit.com
The personal data we would like to collect from/process on you is:
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Personal data type: |
Source (where Open Air Fit Limited obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources): |
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Name, Address, Telephone number, email |
Direct from clients |
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Date of Birth/Age |
Direct from clients |
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Credit/Debit Card Details |
Direct from client |
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Pertinent medical conditions to carry out sporting activities |
Direct from client |
The personal data we collect will be used for the following purposes:
- Carrying out services purchased by client
- Communication
- Receiving payment
- Marketing of future events
Our legal basis for processing for the personal data:
- Consent
- Contractual Obligation
Any legitimate interests pursued by us, or third parties we use, are as follows:
- None
The special categories of personal data concerned are:
- Health/Fitness information
3.2 Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Open Air Fit Limited to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by written instruction GDPR DOC 2.7A.
3.3 Disclosure
Open Air Fit Limited will share your personal data to third parties. The following third parties may/will receive your personal data for the following purpose laid out above as part of the processing activities:
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Organisation (Location) |
Safeguards in place to protect your personal data |
Retrieve a copy of the safeguards in place here: |
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Ticket Tailor (UK Based) |
Encryption using SSL Technology Passwords/API Key |
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Mail Chimp (USA Based |
EU-US Privacy Shield Framework Encryption |
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Stripe (Global) |
EU-US Privacy Shield Framework Encryption |
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Google (Global) |
Encryption using SSL Technology EU-US Privacy Shield Framework |
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Xero (Global, NZ base) |
Minimisation EU-US Privacy Shield Framework Encryption |
3.4 Retention period
Open Air Fit Limited will process personal data for as long as your account is open and will store the personal data for 2 years since last transaction if account is closed. Refer to GDPR DOC 2.3 Retention Period Procedure.
3.5 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Open Air Fit Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
3.6 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Open Air Fit Limited (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Open Air Fit Limited’s data protection representatives Compliance Manager / Compliance Manager.
The details for each of these contacts are:
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Supervisory authority contact details |
Compliance Manager |
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Contact Name: |
Information Commissioner’s Office |
C Hitchcock |
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Address line 1: |
Wycliffe House |
Open Air Fit Ltd |
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Address line 2: |
Water Lane |
Unit 3.15 Chester House |
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Address line 3: |
Wilmslow |
1-3 Brixton Road |
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Address line 4: |
Cheshire |
London |
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Address line 5: |
SK9 5AF |
SW9 6DE |
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Email/Website: |
info@openairfit.com |
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Telephone: |
0303 123 1113 |
3.7 Privacy statement
Read more about how and why we use your data here https://openairfit.com/privacy-policy/
4. Online privacy statement
Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information
This privacy notice tells you how we, Open Air Fit Limited, will collect and use your personal data for:
- Providing fitness classes and programs you have booked
- Keeping you informed of any changes to your class/program
- Processing payment
- Keeping you informed of future pertinent events
Why does Open Air Fit Limited need to collect and store personal data?
In order for us to provide you with a fitness class/program we need to collect personal data for correspondence purposes and service provision. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Open Air Fit Limited would contact you for additional consent.
Will Open Air Fit Limited share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Open Air Fit Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Open Air Fit Limited’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Open Air Fit Limited use the personal data it collects about me?
Open Air Fit Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Open Air Fit Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Open Air Fit Limited contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Open Air Fit Limited at your request, can confirm what information we hold about you and how it is processed. If Open Air Fit Limited does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Open Air Fit Limited or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Open Air Fit Limited accepts the following forms of ID when information on your personal data is requested:
Passport, driving licence, utility bill (from last 3 months).
Contact details of the Compliance Manager / Compliance Manager:
Compliance Manager contact details
Contact Name: C Hitchcock
Address: Open Air Fit Ltd, Unit 3.15 Chester House, 1-3 Brixton Road, London, SW9 6DE.
Email: info@openairfit.com
Document Owner and Approval
The Compliance Manager is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.
A current version of this document is available to all members of staff on the company database and is published in the GDPR Master-File.
Signature: C Hitchcock Date:10/05/18
Change History Record
|
Issue |
Description of Change |
Approval |
Date of Issue |
|
001 |
Initial issue |
Director |
10/05/18 |